The Fourth Circuit Court of Appeals recently held that a CGL policy did not cover a club member’s liability for unintentionally shooting another member while hunting at the insured club. Marks v. Scottsdale Ins. Co., 2015 WL 3940854, at *1 (4th Cir. June 29, 2015).

After being unintentionally shot by another member while hunting on land leased to a hunt club, the underlying claimant sued both the shooter and the club. The club’s CGL insurer denied coverage because its policy did not cover members for their personal recreational activities. In ensuing litigation, the district court entered summary judgment in the insurer’s favor.

The Fourth Circuit affirmed, holding that the policy’s endorsement covering members “with respect to [member] liability for [the Club’s] activities” unambiguously restricted coverage to situations involving a member’s vicarious liability for the activities of the club as an entity. It further held that to qualify for coverage, a member’s activity must have been performed for the club, and rejected the argument that the shooting should be covered merely because it occurred during a club activity.